From:

Eye in the Sky Inc.

Joseph M. Davis

3820 Ron Rd

Green Cove Springs, FL 32043

904-838-5414

jmdavisiphone@att.net

To:

Federal Aviation Administration

I hereby submit a petition to for exemption or waiver from 14CFR § 11.81 Section

333 UAS.

I am Chief Operating Officer of Eye in the Sky Inc. and the corporation currently owns a Yuneec 500Q-4K

quadcopter.

Eye in the Sky Inc. is seeking relief from section 333 in order to operate a Micro UAS on a for profit 

commercial basis. This request is being submitted in order to permit Eye in the Sky Inc. the ability to provide 

professional aerial photography for Real Estate purposes, home builders, property development companies, 

event organizers and property owners. These professional pictures can be beneficial in defining property value, 

usage and elevation relief. In the sale of Real Estate, prospective buyers are requiring more and more 

information in order to make an informed decision about the property they are considering . As property values 

go up, it is necessary for prospective buyers to see what they are buying , and adequately assess the value of the 

property. In years past, in order to obtain good aerial photos of a property it required someone with a manned 

aircraft to fly above the property . Through the use of aerial video, event organizers can promote those events 

without posing unnecessary risks to the public. Completing these types of task through the utilization of an 

unmanned UAS, it will help to improve and ensure the safety of the public by reducing the exposure to much 

larger and dangerous manned aircraft as well as reducing the carbon emissions placed in the atmosphere by the 

larger, fuel burning manned aircraft. The use of a Micro UAS will also allow prospective buyers/developers of 

the property, views of lower elevation terrain that are not possible with the use of larger aircraft.

Eye in the Sky Inc. will ensure proper usage of the UAS systems by requiring the logging of all UAS flight time 

in standard pilot flight logs. Currency will be maintained by all operators through the requirement to perform 

and log a minimum of 2 UAS flights per month.

The following are the specifications of the Micro UAS to be used.

Hardware:

Size - 23inches in Diameter including propellers

Weight - 3.75lbs with camera mounted

Maximum Flight-time – 25+/- minutes 

Transmitter operating frequency - 10-channel 2.4GHz with 5.8GHz video downlink

Maximum Travel speed - 22mph/35kph

Communication Distance of 985 Feet with Rage Extender
Installed Software:

Dynamic return to take off location if communication is broke or low battery is detected

No Fly Zone coverage that is FAA compliant (per manufacturer)

No Fly Zone feature also prevents flight above 400’ AGL

Based on the provisions set forth in the FAA’s proposed rulemaking documentation, Eye in the Sky Inc. will not 

exceed the operational limitations set forth in this document

 Based on the equipment listed above we will operate a Micro UAS that weighs less

than 4lbs

 The VLOS (Visual Line of Sight) rule for Eye in the Sky Inc is limited to maintaining VLOS at all times 

of the UAS operator with no enhanced visual aids

 Flight of the Micro UAS will be done with the permission of all parties associated

with the property that will be filmed and at no time will we fly the Micro UAS directly

over a person without prior knowledge and permission

 The Flight of the Micro UAS will not be operated during non-daylight hours and will

only be flown in visual flight rules (VFR) conditions 

 Although a First Person view camera will be used in the aid of taking pictures it will

not be used to guide the flight

 The limitation of the Micro UAS to be flown at no more than 35mph will not be exceeded due to 

airframe/power limitations as stated in vehicle specification above

 The Micro UAS will not be flown any higher than 200 FT above ground level and will be operated

within Class G airspace at all times

 The Micro UAS will be inspected prior to every flight for safe operation including but

not limited to battery condition, operations of electric motors, GPS, RF Controller, propellers, and RF

connection between Micro UAS and Controller.

 Based on Software installed the Micro UAS will not be flown within a 5mile radius of

any Class A, B, C, D, or E airspace

 Safety will be priority over pictures. If any flight will pose a safety hazard to any person,

animal, structure, aircraft, or the environment, the flight will be immediately cancelled until such time

continued safe operations can be assured

 Operator will maintain a GPS signal with the Micro UAS at all times during the flight. If

connection is broken the equipment's built in GPS system will return the Micro UAS to

the initial take off point and land it safely. If that system is broken for any reason an

emergency land will take place lowering the Micro-UAS to the ground.

Furthermore, by following the above operational limitations that Eye in the Sky Inc. has imposed on all flight

operations, UAS operations will not be posing any risk to the public, environment, or to wildlife.

Since Eye in the Sky Inc. will meet or exceed the operational limitations that are set forth by the FAA as well as 

the companies own operational limitations, I hereby request exemption or waiver from 14CFR § 11.81 Section

333 UAS.

Please contact the addressee above if additional information or documentation is required.

Joseph M. Davis

COO, Eye in the Sky Inc.